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                          August 7, 2023

       Vincent J. Angotti
       Chief Executive Officer
       AcelRx Pharmaceuticals, Inc.
       25821 Industrial Boulevard, Suite 400
       Hayward, CA 94545

                                                        Re: AcelRx
Pharmaceuticals, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed August 2,
2023
                                                            File No. 333-273589

       Dear Vincent J. Angotti:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you
       that the company and its management are responsible for the accuracy and
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

                                                        Please contact Tyler
Howes at 202-551-3370 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              John T. McKenna, Esq.